Letter from 86 Organizations to Vice President Pence: Urgent Actions Required to Mitigate COVID-19 Impacts in Nuclear Energy Industry

As posted on the NIRS website. This letter, sent by Beyond Nuclear and 85 allied groups, was submitted on Earth Day's 50th anniversary, April 22, 2020.

One of the issues raised is impacts of Covid-19 on nuclear power plant emergency preparedness. After all, a mass evacuation, as into evacuation shelters, does not jibe with stay-at-home, stay-safe, shelter-in-place orders in effect in many states due to the Covid-19 pandemic.

NRC seeks to shrink, even eliminate, dedicated offsite emergency planning for US reactors

Flooding at Cooper Station encroached on safety-related electrical circuits / Credit: Light HawkThe U.S. Nuclear Regulatory Commission (NRC) is moving forward with a proposed rulemaking to eliminate its requirements for offsite emergency preparedness around a new generation of Small Modular Reactors (SMR) and other contemplated non-light water reactors. The NRC staff acknowledges that the rule change could also apply to aging, large conventional light water reactors in the US, the brunt of which have had their licenses extendedby decades.

The federal nuclear agency publicly posted the Commission's approval and Vote Record (NRC Accession No. ML19353C623) on January 2, 2020 for its “Proposed Rule: Emergency Preparedness for Small Modular Reactors and other New Technologies” (SECY-18-0103). With only one design (NuScale) currently under review by the NRC, many government and public stakeholders see the vote as premature given the agency has yet to certify the safety of  a SMR design. The rule, if adopted, would base the size of the radiological emergency planning zone (EPZ) on a mathematical model of the projected dose of radiation to the public from a “credible” nuclear accident that would exceed 1 REM.  Even though current SMR design concepts and economical models are based on constructing a single control room to operate multiple, individual “modular” units on the same site , the “credible” accident scenario is limited to  a single unit having an accident no matter how many contiguous units are actually operating at the site.

The Commissioners voted 3 to 1 (one vacant Commission seat) to publish the proposed rule in an upcoming Federal Register which will commence a 60-day public comment period.  Commissioner Jeff Baran cast the lone vote to oppose the rule as written. Commissioner Baran warns that the proposed rule is “flimsy” when compared to current emergency planning and reverses four decades of agency practices where emergency preparedness and evacuation planning for surrounding communities within a 10-mile radius of all conventional atomic reactor sites is the last line of a  “defense-in-depth” philosophy of multiple layers of defense.  The rule change explicitly permits the nuclear utilities’ emergency preparedness plan to be limited to the reactor site’s fence line.

Without offsite radiological emergency planning, the role of the Federal Emergency Management Agency (FEMA) to evaluate the adequacy of a site's emergency plans would be diminished if not eliminated. The draft proposed rule would further eliminate the requirement for ”ingestion pathway zones” (IPZ) established to  prevent and minimize radiological exposure to surrounding populations  out to a 50-mile radius around conventional light water reactors.  The NRC would no longer require a specific drill frequency for emergency planning exercises or a coordinated response between the federal, state and local emergency response agencies around new proposed SMR facilities.

Commissioner Baran’s dissenting comments reveal that FEMA, the federal agency responsible for disaster planning,  has identified several significant problems with the NRC draft rule including the NRC and industry’s mathematical methodology can be applied to larger US reactors to shrink the EPZ and reduce the cost of the current level of readiness and radiological protection for the surrounding civilian populations. The NRC staff is in fact explicitly asking for public comment on the agency adopting the use the same formulaic approach to reduce emergency planning zones around the nation’s larger, aging light-water reactors.

The FEMA critique points out that the NRC draft rule does not consider a “credible” nuclear accident would affect more than one SMR module despite present design concepts that use a common control room for multiple, contiguous units located on the same site. The NRC staff argues that their new EPZ sizing methodology only applies singularly to each reactor unit in isolation. However, Commissioner Baran and FEMA recognize that the new methodology ignores how severe natural disasters (earthquake, flood and other extreme events) can simultaneously damage multiple reactors at a site as happened at Japan’s Fukushima Daiiichi nuclear power station following the severe earthquake and tsunami. While each individual SMR would be 300 Megawatts electric or less, the combined power and thermal output of two or more SMRs can be cumulatively larger than some existing large light-water reactors.

Monstrous hurricanes reveal serious flaws in U.S. nuclear emergency plans

One record-breaking “100-year hurricane” after another battered the U.S. Gulf Coast region, first in Texas and then Florida, affecting six reactor units at three nuclear power stations, just two weeks apart. Hurricanes Harvey and Irma are demonstrating the devastating cost and consequences of increasingly extreme weather and climate change.  But ponder how much worse the human suffering, economic losses and an already astronomical cost of recovery could have been if these hurricanes had triggered nuclear accidents and radioactive contamination like Japan’s Fukushima Daiichi nuclear accident. It was that radioactive catastrophe that blocked the emergency response to those trapped as victims of the natural disaster and stifled the recovery to date.

Beyond Nuclear had called upon the nuclear industry and the Nuclear Regulatory Commission (NRC) to prudently protect public health and safety by shutting down the six nuclear generator units well in advance of the hurricanes’ making landfall. The group wanted those six reactors in the safest and most reliable condition, cold shutdown, before experiencing hurricane conditions. At first, the operators feinted they would shut down the atomic power plants, then abruptly reversed their decisions and operated the units as the massive storms slightly altered course, brushing the reactors. In the end, South Texas Project Units 1 & 2 operated throughout Hurricane Harvey. Florida Power & Light shut down Turkey Point 3 in advance of Hurrican Irma’s arrival but kept Unit 2 operational until a main feed water valve tripped, possibly on a split second perturbation on the electric grid, causing the unit to SCRAM. St. Lucie 1 & 2 operated at 100% power until salt starting caking in Unit 1’s switchyard prompting the operator to power that unit down.

None of the Texas and Florida reactors experienced sustained winds in excess of 73 mph that would have required shutdown. None of the six units experienced complete “loss of offsite power” with grid failure which is supposed to automatically shut down the reactors. The reactors never experienced “the loss of ultimate heat sink” where the reactors cooling water pumps fail from storm surge.  But none of this means that the operating reactors were immune storm hazards, with the reactors pressurized to 2000 pounds per square inch so that water temperature in the steam generators primary coolant loop was maintained at 600^o Fahrenheit. 

Both hurricanes’ spawned tornadoes that suddenly drop down out of rain bands and thunderstorms without warning. In Texas, Harvey fostered 317 tornado warnings, more than the last two years combined for the entire state. Thirty tornadoes were reported on the Texas Gulf coast. The incidents of tornadoes generated by Irma is still being tallied but, “Two thunderstorms capable of creating tornadoes have also been spotted over the Saint Lucie Nuclear Power Plant.” Tornadoes can initiate a loss of offsite power and their high winds generate missiles threatening safety-related systems. In 1992, wind-blown missiles from Hurricane Andrew punctured an onsite oil storage tank spilling 110,000 gallons of combustible fuel over the reactor site and toppled a high tank simultaneously destroying the reactors’ fire protection system. Luckily, there was no ignition that might have caused a significant fire at the reactor site where just such an event provides 50% of NRC’s recognized risk for initiating a reactor meltdown.

Beyond Nuclear is concerned not just about extent of plant site conditions with a hurricane direct hit. The size and ferocity of these storms demonstrated impacts on the nuclear power stations’ radiological emergency planning zones that can extend well beyond the designated 10-mile radius “evacuation planning zone” and a 50-mile radius “ingestion planning zone.”

The state and federal nuclear emergency plans do not adequately account for unrealistic evacuation time estimates for a nuclear accident. Populations in harm’s way from the hurricane had days, even weeks to prepare to evacuate. A nuclear accident may only provide a matter of hours to escape radiation exposure.  Radiological emergency planning for the simultaneous occurrence of natural disaster and nuclear catastrophe does not account for a storm impeding evacuation by blocking escape routes with debris and flooding. The designated “reception centers” outside of the 10-mile emergency planning zone for receiving and decontaminating evacuees from a nuclear disaster could experience storm conditions prompting “mandatory evacuation” of the centers. Bay City, Texas, one of two reception centers for South Texas Project, was under mandatory evacuation orders for several days in anticipation of flooding up to ten feet. Designated first responders such as doctors, hospital workers, first responders and evacuation bus drivers would not have been available for a radiological emergency. Houston firefighters were not available as designated to respond to an emergency at the nuclear power station.  

The Florida reception centers are designated for post-nuclear accident distribution of potassium iodide (KI). KI is administered for safe and effective protection of the thyroid from exposure to cancer-causing radioactive iodine-131, one of the fastest traveling radioactive gases released during a severe accident at a nuclear plant. Beyond Nuclear supports the American Thyroid Association recommendation to pre-distribute KI directly to populations within the 50-mile radius of nuclear power stations and stockpiling out to 200 miles in schools, hospitals and police stations. In this way, vulnerable populations can take KI as soon as notified, especially if reception centers are inaccessible or inoperable. However, Texas is one of seven states that does not even stockpile KI and is without a distribution plan for prophylactic protection of those most vulnerable populations of infants, children and pregnant women.   

Gambling with the odds of a nuclear accident and its radioactive consequences, however remote, for the sake of saving the nuclear industry some money and prioritizing its power agenda over public health and safety is increasingly unacceptable. The growing availability of safe, affordable and clean renewable energy further makes nuclear power and its threat increasingly unnecessary.

Listen to more on the hurricanes' impacts on the nuclear power stations on "The Nuclear Hotseat."

"Nuclear Evacuation Preparations in Question for Chicago Area Communities"

NBC 5 investigative reporter Chris Coffey has looked at the Disaster Accountability Project's findings and applied them to Exelon's atomic reactors in Illinois. Major gaps are apparent, especially in the 10- to 50-mile zones around atomic reactors.

The U.S. government warned Americans in Japan to get at least 50 miles away from the Fukushima Daiichi nuclear power plant, once the radiological catastrophe began there in March 2011.

The report quotes Beyond Nuclear: “They are not ready for the flood of nuclear evacuees that would flow out of the 10-mile Emergency Planning Zone and seek shelter in their communities, not to mention potentially large numbers of spontaneous 'shadow' evacuees who would also flee in panic, despite no official orders to do so,” said Kevin Kamps of Beyond Nuclear.

Lochbaum at UCS: "Fukushima 50 vs. Palisades 40"

David Lochbaum, Director of the Nuclear Safety Project at Union of Concerned Scientists (UCS) communicated the following to Beyond Nuclear:

"The NRC has been withholding from the public all emergency plans submitted by owners since October 2004, apparently part of the agency's transparency thingy.

So, I FOIA'ed all the emergency plans submitted by owners since October 2004, as part of our transparency thingy.

Attached are three pages from the latest version of Palisades' emergency plan (full plan available - now - in ADAMS at http://pbadupws.nrc.gov/docs/ML1430/ML14301A176.pdf)

It shows the minimum staffing levels and augmentation plans for Palisades in event of an accident.

Excluding security guards, the minimum staffing level is 14.

That massive force, larger than the offensive team on an NFL football squad, is supposed to be augmented by 11 more persons within 30 minutes and another 15 persons within another half hour.

So, within 60 minutes of an accident, a whooping "army" of 40 persons (excluding security guards who, having both guns and cars, might actually be physically excluded) to handle the accident. 

That's fewer persons than in a high school band or NFL football team.

Much was made during the Fukushima accident about TEPCO dropping the onsite staffing level to "only" 50 - or two basketball teams more than Palisades staffs "up" to.

But there's a silver lining, or glass half full.

40 persons, unless they really work at it, will make fewer mistakes than 200 people. True, they don't be able to do nearly as much work as 200 people, but way less work means way less errors of commission. (Errors of omission hurt, but aren't counted here.)

And here's the other half of that there glass.

The 40 persons are not mere mortals. They must be super heroes, or better.

Take a gander at page two under the "Repairs and Corrective Actions" task. There is one (1) person performing Mechanical Maintenance repairs, aided by a second super hero within an hour.

Two people doing mechanical maintenance repairs following an accident.

They have to be super heroes. Routine tasks during the week take dozens of mechanical maintenance workers. But during an accident, workers must become super workers.

Look at the electrical maintenance repairs. They have 50 percent more staff -- three super workers instead of only two.

Remind me to someday get the autographs of these super workers.

During the week, non-super workers need clerks to find and fetch parts from the warehouse and obtain copies of appropriate work procedures. But during an accident, super workers can do their tasks as well as tasks of the warehouse clerks and document control room staff.

And these super workers will save the day in event of an accident.

Unless an accident occurs to reveal 40 humans.

Thanks,

Dave Lochbaum

UCS".